Tax dispute resolution

Preventing disputes before they arise and successfully resolving challenges by tax authorities.

Sharon Katz-Pearlman

Sharon Katz-Pearlman

Principal-in-Charge, Tax Dispute Resolution, KPMG US

+1 212-872-6084

Preventing disputes and resolving challenges

Increased pressure on tax authorities to generate revenue has resulted in a growing number of examinations of returns and expanded audit activity, across all jurisdictions and types of tax. Frequently, this can mean significant adjustments with increased penalty potential.

When considering an upcoming examination, companies must consider a number of critical questions including overall preparedness for the examination, and appropriateness of documentation. And, if you have already been contacted, or an assessment has already been made, how will you resolve it?

We work collaboratively with you

Our Tax Dispute Resolution professionals have assisted companies around the world in preventing, preparing for and responding to challenges by tax authorities.

Working collaboratively with you before, during, and after the tax examination process, we can save you time and potentially costs by assisting you in the following areas:

  • Tax examination risk analysis
  • Documentation preparation
  • Tax return disclosures
  • Information reporting and tax withholding requirements
  • Official requests for information
  • Appeal processes, mediation and arbitration
  • Penalty and interest mitigation

What sets us apart

When working with us, you'll come to realize what sets us apart. We believe you will benefit from our: 

  • Industry knowledge: Our dispute resolution teams have extensive knowledge of the complex procedures followed by global revenue authorities.
  • Global connectivity: We assist on all sides of the dispute to help ensure consistency of argument and position.
  • Full-service approach: We embrace a side by side and end-to-end approach to working with clients.



Now Available! KPMG's 2018 Tax Dispute Resolution Benchmarking Survey Report

Read our report findings, based on a survey taken by tax professionals from over 150 companies, and see how in-house tax disputes professionals are responding to controversy challenges in a dynamic disputes environment.

Recent developments:

Clarity Provided for Timing of Revenue Under the Accrual Method

Recently-issued proposed regulations under Code sections 451(b) and 451(c) and (2) Rev. Proc. 2019-37 provides procedural guidance for requesting a change in accounting method to comply with the proposed regulations. The proposed regulations are helpful for purposes of determining when an item of revenue that is accelerated in a taxpayer’s AFS requires a corresponding acceleration of recognition for income tax purposes. However, there are several unanswered questions (discussed in Section III, p. 62) that we hope Treasury will address in the final regulations.


For more information about our services:

Tax Controversy Services
For any business or taxpayer preparing for or facing an Internal Revenue Service (IRS) examination, appropriate strategies for response and compliance are critical.

In Dispute podcast series

Our monthly podcast series reveals the latest insights and hot topics in the world of tax controversies.

Tax Dispute Resolution Quarterly

Aggregates hot topics, uncovers dominant trends, and offers insight from our TDR Network.

Tax Audits and Disputes

Stay informed on the latest insights in tax disputes and resolution.